The Tribunal examined whether a large consultancy payment was allowable when the assessee failed to establish its genuineness and business necessity. It upheld the disallowance, holding that mere claims without credible evidence cannot justify deduction of professional expenses.
The assessing authority made a large addition without explaining its nature or legal basis. The Tribunal ruled that such a cryptic order cannot stand and set aside the addition.
The Tribunal observed that the transfer pricing adjustment was based on unexplained margin calculations. A fresh working was directed to ensure accurate benchmarking of international transactions.
The Supreme Court held that purchasers who acquire property during pending litigation are bound by the decree and cannot obstruct execution of possession. Transfers made pendente lite remain subservient to the final decree and do not create independent rights against the decree holder.
The Tribunal held that reopening completed scrutiny assessments beyond four years is invalid when reasons do not allege failure to disclose material facts. The key takeaway is that Section 147’s first proviso is mandatory and cannot be bypassed.
The Tribunal held that reassessment notices issued by the jurisdictional officer violated the mandatory faceless regime under Sections 144B and 151A. Non-compliance with the prescribed faceless procedure renders the entire reassessment void ab initio.
The Court found that the explanation regarding dividend income was on record but not examined. Reopening based on an incorrect recording of facts was held to be invalid.
The issue was whether a DRP-based assessment passed after the statutory period survives. The Tribunal held the delay fatal and quashed the assessment in entirety.
The issue was whether settled losses could be ignored in a search assessment without incriminating material. The Tribunal held that the AO must start from the last assessed income and allow already determined losses.
The issue was erroneous recomputation of LTCG causing double taxation. The Tribunal held that credit for LTCG already declared must be given and indexation cannot be curtailed arbitrarily.
